AFS-10-133-E 

Sep 30 2010 

 Exemption No. 9837A 

 Regulatory Docket No. FAA-2009-0111 

Mr. Michael Daigneault 

Director, Flight Standards 

CitationShares Management LLC 

5 American Lane 

Greenwich, CT 06831 

Dear Mr. Daigneault: 

This letter is to inform you that we have denied your petition to amend Exemption No. 9837. 

It explains the basis for our decision, describes its effect, and lists the conditions and 

limitations. 

The Basis for Our Decision 

By letter dated January 7, 2010, you petitioned the Federal Aviation Administration (FAA) on 

behalf of CitationShares Management LLC (CitationShares) for an amendment to Exemption 

No. 9837. That exemption from § 135.255(f)(1) of Title 14, Code of Federal Regulations 

allows CitationShares to make instrument flight rules (IFR) takeoffs from foreign and military 

airports when the visibility is less than 1 statute mile or make an instrument approach when 

the visibility is less than 1⁄2 mile. The amendment request would extend the provisions of this 

exemption to include all turbojet-powered aircraft operated by CitationShares. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested amendment to the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to CitationShares. 
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Our Decision 

CitationShares requested to amend its exemption by including all turbojet-powered aircraft to 

its current exemption. CitationShares states that all of its aircraft are type certificated under 

part 23 or 25 and that the addition of all turbojet aircraft would not decrease the level of 

safety. CitationShares states that future turbojet-powered aircraft, regardless of aircraft, will 

be of the same classification and will be approved per its existing part 135 operations 

specifications prior to commercial operation. In addition, CitationShares states that aircraft 

operations conducted by the petitioner either meet or exceed all part 135 requirements. 

The FAA granted CitationShares’ current exemption based on Exemption No. 9752 that was 

previously issued to NJI, Inc. That exemption was based on NJI’s operation of state-of-the-art 

avionics, navigation systems, flight guidance systems, and displays and that all NJI operations 

were conducted with two pilot crews. 

You request that all turbojet aircraft type certificated under parts 23 and 25, operated by 

CitationShares without regard to state-of-art avionics, navigation systems, flight guidance 

systems, and displays or the number of crew conducting flight operations, be included in the 

exemption. 

The FAA finds that your amendment request is too broad to show how the proposed 

amendment of Exemption No. 9837 would provide a level of safety equivalent to that 

provided in the affected section of the previously granted exemption. In addition, the FAA 

notes that your amendment request does not provide how it would be in the public interest. 

The FAA has determined that the justification for the issuance of Exemption No. 9837 

remains valid with respect to this exemption and is in the public interest. Therefore, under the 

authority provided by 49 U.S.C. 40113 and 44701, which the FAA Administrator has 

delegated to me, I deny your amendment request. The conditions and limitations remain the 

same. 

Conditions and Limitations 

1. Provisions of this exemption apply to Citation CJ3 (CE-525B), Citation Bravo (CE-550B), 

 Citation Excel/XLS (CE-560XL), and Citation Sovereign (CE-680) aircraft only. 

2. Crews utilizing this exemption must have been trained and qualified to the standards 

 specified under part 121, subparts N and O. 

3. Airports at which CitationShares intends to utilize the provisions of this exemption must 

have had approach procedures developed in accordance with U.S. Terminal Instrument 

Procedures or International Civil Aviation Organization Procedures for Air Navigation 

 Services criteria. 

 
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The Effect of Our Decision 

The termination date of Exemption No. 9837 remains March 31, 2011, unless sooner 

superseded or rescinded. 

All conditions and limitations of Exemption No. 9837 remain the same. This letter must be 

attached to, and is a part of, Exemption No. 9837. 

Sincerely, 

/s/ 

Raymond Towles 

Acting Director, Flight Standards 

 Service